TL: Greenpeace Statements on Ocean Mining, to Oregon TaskForce SO: Carol Alexander, Greenpeace USA (GP) DT: July 22, 1990 Keywords: oceans ocean mining sea bed greenpeace statements us gp / Greenpeace USA * 4649 Sunnyside Ave. N * Seattle WA 98103 ========================================================= To: OREGON PLACER MINERALS TASK FORCE FROM: CAROL ALEXANDER, OCEAN ECOLOGY CAMPAIGNER DATE: JULY 22, 1990 RE: 1990 PLACER MINERALS CRUISE FOR EXPLORATION OF OFFSHORE PLACER DEPOSITS Please accept the following comments on behalf of the two million supporters of Greenpeace USA. During the past year, Greenpeace has offered comments to the Oregon Ocean Resources Management Task Force regarding its draft plan for ocean resources management. Those comments included repeated expressions of opposition to exploration and development of offshore placers. It was our understanding that the Placer Task Force was privy to and guided by the information collected by the Oregon Ocean Task Force, but as this seems not to be the case, we are reiterating our concerns to you now as an expansion of my verbal comments to you at the Placer Task Force meeting in Gold Beach, Oregon on July 17, 1990. Greenpeace is firmly opposed to any attempts to explore for and exploit marine minerals from Oregon's continental shelf, for the following reasons: Oregon's land use planning goal #19 clearly prioritizes renewable ocean resources over nonrenewables. Dredging 60 to l00 meter swaths of the benthos for 24 hours a day year-round would certainly disrupt benthic communities and potentially degrade commercial fisheries. It would increase turbidity and trace metal content and decrease oxygen levels in the water column. Dredging operations of this magnitude would likely alter sand budgets and change littoral dynamics. The areas identified for a potential mining operation contain vulnerable seabird colonies and crucial marine mammal haul-out sites, as well as the largest reproductive population of Steller sea lions in the lower 48. According to the Minerals Management Service (MMS), "Human activities associated with mining operations - especially air traffic - are known to disturb birds.' Similarly, MMS states that "noise and movement of aircraft and support vessels associated with mining operations, as well as dredging activities and exploration sediment-core drilling are likely to affect" marine mammals in the area of a similar type of mining operation proposed for Norton Sound, Alaska. The dubious economic worth of strategic minerals thought to be present in Oregon offshore placer deposits in no way justifies the risk to wildlife, marine habitats, renewable resources and the sustainable coastal industries dependent on them. The argument presented by mining proponents that placer extraction is necessary in order to preserve national security cannot be seriously entertained: chromite is identified as the mineral of highest strategic importance, but the high-iron chromite present in southern Oregon placers could not be used by the metallurgical industry (where it is considered strategic because of its use in steel alloys), only by the chemical industry for such things as paint production. Even should higher quality and greater quantities of strategic minerals exist offshore Oregon, it would be exceedingly difficult to justify their exploitation when metals such as chromium and titanium exist in the industrial and municipal waste stream with little effort made towards recycling. One dumpsite alone offshore New York is estimated to receive 930,000 lbs of chromium every year. Should economically recoverable gold be defined, enormous quantities of sediment would have to be dredged and processed to produce minute quantities of gold. For example, the Norton Sound DEIS predicts that the gold mining operation proposed there would result in 25,000 dry metric tons of sediment discharged every day from one dredge ship, and that only 530,000 troy ounces of gold could be recovered from dredging 40 million cubic meters of sediment in 800 acres. Impacts to the benthos, water column, commercial fisheries and near shore dynamics could be severely impacted by such a dredging scenario offshore Oregon where virtually nothing is known about ocean circulation in the region. Historically, preferred processing techniques have involved mercury amalgamation or cyanide leaching, both of which raise grave environmental concerns whether conducted at sea or on land -and all for a luxury commodity. As long as research and exploration are focused on delineation of placers, interested individuals, agencies, organizations and businesses must remain involved, committing time and resources to monitor the direction and intent of what can only be viewed as a development-oriented process. If a genuine need for these minerals could some day be demonstrated, and if state and federal agencies are mandated to provide them, let research efforts and funding be directed towards conservation and recycling potential of metals already extracted and processed, in use or in the waste stream. Greenpeace opposes the MMS-funded 'Aloha' cruise scheduled for September 1990 for the following reasons: The State of Oregon currently has no permitting process established for non-commercial exploration of offshore non-renewable resources. SB 606 addresses exploration contracts and defines the permit and public review process. The Placer Task Force has insisted in response to public queries that the Aloha will not be involved in exploration, but in research, and therefore not required to provide formal environmental assessment with public review and comment, a permit process, nor an inventory and effects assessment as required by Oregon land use planning goal. Greenpeace fundamentally disagrees with the assertion that the Aloha proposal is one of research (i.e. non-exploration). According to the "Recommended Cruise Plan" which will be funded by MMS in the amount of roughly $195,000: The objective of the 1990 field program is to successfully identify the concentration, quality and distribution of placer minerals with depth in the sand section in at least two targets on the Oregon Shelf and, concurrent with this examination, collect information on living resources and geology that will benefit further considerations if the potential for economic placer deposits appears favorable. When one examines this statement in the context of the stated goal of MMS' Office of Strategic and International Metals, "Developing the potential of the OCS as a domestic supply source for hard minerals," in concert with the known convivial relationship between MMS and industry in the OCS oil and gas leasing program, it is a stretch of credulity to accept the statement that the Aloha cruise is only academic research and not exploration. What Greenpeace perceives in the Aloha proposal is an exploration venture funded by MMS, involving an exploratory process that could in and of itself negatively impact the marine environment, and one that is occurring without state permit, without public review and comment, without an environmental impact statement. For the State of Oregon to allow this venture to proceed without a legal structure in place is not only to put the cart before the horse, but to give the cart a downhill push. The EA (Environmental Assessment) prepared by MMS and made available at the July 17, 1990 Task Force meeting in Gold Beach is an incomplete, inadequate assessment. The EA does not even mention endangered add threatened species; it does not describe the habitat and species assemblages in any but the most cursory fashion (one page for water quality, one for benthic resources, two for commercial and sport fisheries, and a half page for cultural resources!). The section 5.0 for Consultation and Coordination states, "This section describes the consultation and coordination that was conducted by the MMS in the preparation of this EA," and then proceeds to merely list three federal agencies and two state agencies on an otherwise blank page. Interestingly, at the task force meeting on June 17, I happened to be seated next to Mr. Palmer Sekora, Regional Refuge Manager for the U.S. Fish & Wildlife Service National Wildlife Refuge Branch and the individual responsible for managing the offshore rocks and islands of the National Wildlife Refuge system, some of which are in the vicinity of the placer deposits. Mr. Sekora had never seen nor heard of this EA until that day, although the U.S. Fish & Wildlife Service was one of the three federal agencies listed for consultation. When questioned regarding the inadequacy of the EA at the July 17 task force meeting, MMS officials responded by stating the EA only addressed the immediate impacts of the "research" and defined it as an isolated event separate from a development oriented process. However, the EA states, "The acquisition of the data resulting from this cruise will better enable regulatory agencies from both the State of Oregon and the Federal Government to prudently determine the future development of the offshore Oregon placer deposits." The semantic discussion could be enlarged and continued, no doubt. It seems clear that when one considers the extraordinary worth of the southern Oregon commercial fisheries, the relatively pristine state of a vigorous and productive marine habitat, the presence of threatened and endangered species (e.g. brown pelicans, Steller sea lions, grey whales), and the clear mandate of Oregon land use planning goal; to protect renewable resources, this is scarcely an appropriate forum for semantic hair-splitting. The State of Oregon should immediately forestall the Aloha proposal until it determines legislatively if this type of federal agency exploration should be permitted within state waters, and if so, by what process. The Placer Task Force has stated that it follows recommendations of the Oregon Ocean Resources Management Task Force (OORMTF). The OORMTF has recommended that Goal 19 administrative rules are needed to spell out the requirements of goal 19 inventory and effects assessment for all phases of marine minerals exploration and development. No administrative rules now exist. Once again, the process is ahead of itself; the Aloha is funded and approved with absolutely no state permit or regulatory process to contain it, including goal 19 administrative rules. The Placer Task Force has attempted to assuage public concern about the purpose of the cruise by assuring us this is also an opportunity for biological assessment. However, of the proposed $197,500 total cost, only $22,356 (or 11%) will be directed towards biological observations. In summary: It was readily apparent at the Gold Beach July 17 task force meeting that the people of southern Oregon are overwhelmingly in opposition to development driven "research" of offshore placer deposits. The task force has been hearing this message loudly and consistently throughout the past year and yet is steadfastly pursuing its agenda. Strangely, task force members have interpreted this opposition as being somehow "anti-knowledge." Greenpeace strongly supports an expanded information base of the ocean and its inhabitants, we support research into conserving and recycling potential of nonrenewable resources, as do most of the individuals and organizations opposing the Aloha venture. Dredging enormous quantities of fragile benthic communities, causing perhaps irrevocable changes in the dynamics of equilibrium before we understand the ecology of benthic communities might be termed anti- knowledge. Pushing forward with a venture which clearly has the goal of stimulating commercial interest in a mining venture (see footnote #9 and the appended MMS information paper) could perhaps be termed anti-knowledge. But again, semantics are not the issue. The immediate issue is that there seems to be no legal justification for the Aloha cruise scheduled for September 1990, and Greenpeace requests it be cancelled immediately. An additional, longer-term issue which can only be briefly mentioned in the context of this memorandum, is the dubious authority of the MMS to actively promote domestic marine mineral mining by the one thin reference in section 8(K) of the Outer Continental Shelf Lands Act. Thank you for the opportunity to comment. cc: Governor Neil Goldschmidt Secretary of State Barbara Roberts State Treasurer Tony Meeker Senator Mark Hatfield Congressman Peter DeFazio The National Audubon Society The Sierra Club Legal Defense, Fund Oregon Shores Conservation Coalition The Natural Resources Defense Council The Oregon Natural Resources Council The American Oceans Campaign Senator Bill Bradbury The Oregon League of Women Voters Pete McHenry, Raymond Collins and Ralph Brown as representatives of the southern Oregon commercial fishing industry. ENDS